The present study analysis the problematic which involve the taxation of residents in individual income tax, towards a recent legislative change, as well as to illustrate the importance of the Supreme Court of Justice and the OECD Model Convention in these modifications, also alluding to the decisions of the Administrative Arbitration Center on this matter, although with some limitations, considering the few existing decisions on this subject. In the end, we will also address the importance of exit taxes, as a legal situation which is created by loss of residence in a determined territory and how this kind of taxes have fought the tax planning through relocation of residence.
|Date of Award||27 Feb 2018|
- Universidade Católica Portuguesa
|Supervisor||Tomás Tavares (Supervisor)|
- Dual residence
- Deemed residence of individuals
- Double tax conventions
- Exit taxes